The environmental risk assessment report must contain information that is necessary to determine the potential financial liability associated with the management of latent environmental liabilities post closure, keeping in mind the proposed post-mining end use, once the initial relinquishment criteria has been achieved and must include─
| (i) | the person or persons that prepared the plan; |
| (ii) | the professional registrations and experience of the preparers; |
| (b) | details of the assessment process used to identify and quantify the latent risks, including– |
| (i) | a description of the risk assessment methodology inclusive of risk identification and quantification; |
| (ii) | substantiation why each risk is latent, including why the risk was not or could not be mitigated during concurrent rehabilitation and remediation or during the implementation of the final rehabilitation, decommission and closure plan; |
| (iii) | a detailed description of the drivers that could result in the manifestation of the risks, to be presented within the context of closure actions already having been implemented during the execution of concurrent rehabilitation or during the implementation of the final rehabilitation, decommission and closure plan; |
| (iv) | a description of the expected timeframe in which the risk is likely to manifest, typically as expected years after closure, and the duration of the impact, including motivation to support these timeframes; |
| (v) | a detailed description of the triggers which can be used to identify that the risk is imminent or has manifested, how this will be measured and any cost implications thereof; |
| (vi) | results and findings of the risk assessment; |
| (vii) | an explanation of changes to the risk assessment results as applicable in annual updates to the plan; |
| (c) | management activities, including─ |
| (i) | monitoring of results and findings, which informs adaptive or corrective management and/or risk reduction activities; |
| (ii) | an assessment of alternatives to mitigate or manage the impacts once the risk has become manifested, which must be focussed on practicality as well as cost of the implementation; |
| (iii) | motivation why the selected alternative is the appropriate approach to mitigate the impact; |
| (iv) | a detailed description of how the alternative will be implemented; |
| (d) | costing, calculated using the current value of money and no discounting or net present value calculations included in the determination of the quantum of the liability, including– |
| (i) | a cost estimation, which must include— |
| (aa) | an explanation of the closure cost methodology; |
| (bb) | an auditable calculations of costs per activity or infrastructure; |
| (dd) | monitoring costs post closure to determine whether the risk is imminent or has manifest are to be included in the assessment as are monitoring costs likely to be incurred during the implementation of the strategy to manage or mitigate the impacts once the risk has become manifest; |
| (ii) | where appropriate, a differentiation between capital, operating, replacement and maintenance costs; |
| (iii) | cost estimates for operations, or components of operations that are more than 30 years from closure prepared as conceptual estimates within an accuracy of ± 50 per cent. Cost estimates will have an accuracy of ± 70 per cent for operations, or components of operations, 30 or less years (but more than ten years) from closure and ± 80 per cent for operations, or components of operations ten or less years (but more than five years) from closure. Operations with 5 or less years will have an accuracy of ± 90 per cent. Motivation must be provided to indicate the accuracy in the reported number and as accuracy improves, what actions resulted in an improvement in accuracy; and |
| (e) | monitoring, auditing and reporting requirements, which must include requirements prior to the manifestation of the risk and impacts as well as those once the impacts resulting from the manifestation of the risk are realised, inclusive of the approach that will be taken to analyse monitoring results and how these results will be used to inform adaptive or corrective management and/or risk reduction activities. |
